In re Child of Angela S., 232 A.3d 215

DHHS filed a petition to terminate Angela S.’s parental rights after prior child-protection involvement for neglect and substance abuse (initial substantiation in 2017; child removed in 2018).
In February 2018 ambulance personnel found the child dirty, foul-smelling, and inadequately clothed; mother was in a residential recovery program she did not complete.
Mother consistently made herself available for visits, but the child refused visits beginning June 4, 2019; the Department and GAL did not force contact.
The juvenile court found mother had ongoing substance‑abuse and mental‑health issues, failed to complete rehabilitation in a timeframe adequate from the child’s perspective, and could not protect the child from jeopardy.
The court found DHHS made reasonable reunification efforts, the child was thriving with foster/resource parents and wanted to remain, the GAL supported termination, and termination was in the child’s best interest.
The court terminated parental rights under statutory grounds and the mother timely appealed; the Supreme Judicial Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for parental unfitness	Angela: record lacks competent evidence to prove at least one statutory ground	DHHS: clear and convincing evidence (prior neglect, substance abuse, unsanitary conditions, inability to protect; failure to complete rehab timely)	Court: competent evidence supports parental‑unfitness finding; affirmed
Whether termination was in child’s best interest	Angela: court abused discretion; termination not in child’s best interest	DHHS: child needs permanency now; mother’s recovery efforts speculative and too late; child refuses visits	Court: no abuse of discretion; termination serves child’s need for permanency
Whether mother made good‑faith rehabilitative efforts timely	Angela: she made improvements and efforts to reunify	DHHS: efforts came too late to meet the child’s needs	Court: even if some improvement existed, efforts were too late; alternative unfitness grounds supported termination
Whether DHHS made reasonable reunification efforts	Angela: arguable that reunification efforts lapsed when visitation stopped	DHHS: reasonable efforts were made; mother did not develop argument	Court: mother’s argument undeveloped/waived; court’s finding of reasonable efforts stands

In re Children of Danielle M., 222 A.3d 608 (2019 ME) (competent‑evidence standard for supporting factual findings)
In re Child of Katherine C., 217 A.3d 68 (2019 ME) (standard for terminating parental rights requires clear and convincing evidence of at least one statutory ground)
In re Children of Christopher S., 203 A.3d 808 (2019 ME) (review standards for best‑interest factual findings and ultimate best‑interest determination)
In re Children of Tiyonie R., 203 A.3d 824 (2019 ME) (child‑centered timing inquiry to assess parent’s ability to protect and take responsibility)
In re Children of Jessica D., 208 A.3d 363 (2019 ME) (permanency is the central tenet in child‑protection best‑interest analysis)
In re Child of Christine M., 194 A.3d 390 (2018 ME) (affirmance may rest on any one adequately supported ground when multiple bases are found)
In re David H., 985 A.2d 490 (2009 ME) (undeveloped appellate arguments are waived)